Privacy policy

Your privacy is important to ZoomJar Technology Inc, the owner of the PharmaGap application, (hereinafter, ” PharmaGap “, ” we “, ” us ” or ” our “). This Privacy Policy (” Policy “) applies to our activities related to our mobile applications as well as our web applications and any services derived therefrom, including the pharmagap.com website (collectively, the ” Application ” or the ” Services Offered “) and describes our personal information collection, use and disclosure practices, as well as the rights you may have with respect to your personal information.

Unless expressly stated otherwise, terms defined in our Terms of Use and used in this Policy have the same meaning as in our Terms of Use.

This Policy applies to personal information collected by PharmaGap, including whether you are a professional or a principal or a representative. This Policy applies whenever you interact with us, including when you access the Application.

1. Definition of “personal information

By “personal information” we mean any information that directly or indirectly identifies an individual (collectively, ” individual ” or ” you “) or could reasonably be associated with that individual. Examples include your name, contact information, e-mail address and account information (as applicable). Please note that information concerning an individual’s position within an organization, such as name, position, work address, e-mail address and telephone number, is not considered personal information.

2. What personal information do we collect?

The personal information we collect may include :

• Identifiers and contact information, such as your name, e-mail address, mailing address, telephone number, IP address (if personally identifiable), device identifier or account information (for example, if you created an account when registering for services) or business license number.

• Browsing activities in connection with the services offered, such as pages and offers viewed, opt-out preferences, e-mail returns, clicks, social media content and IP addresses, if such information identifies you as an individual.

• Geolocation information may be collected when you use the services offered, although this information does not always identify you as an individual.

• Messages, activities and other information shared in the Application’s chat function.

• Any other information you provide to us that identifies you.

3. How do we collect personal information?

We collect personal information in a variety of ways, including directly from you, from technologies used at our locations, through online technologies (for example, when you interact with us through the Application), from third-party social networks and from other third parties. PharmaGap also encourages you to review the privacy policies of third parties. Third parties involved may use tracking methods such as, but not limited to, cookies, to achieve their own business objectives by linking and combining information about your use of the Application with any other personal information they may have collected about you.

Specifically, we collect personal information in the following ways:

A. Directly from you
We may collect personal information directly from you, through the Application, when you create an account to access the Application or when you use the Application, by mail, e-mail, telephone or in any other direct way in connection with the services offered, for example, when you send a request to our customer service department.

B. Through our service providers
We may receive personal information from our service providers. We may also receive personal information from other sources with your consent or where permitted by law.

C. Through online technologies
With your consent or where permitted by law, we may collect certain types of information electronically when you interact with the Application. This information helps us to improve our Application and to understand what you do when you use it, and allows the Application to function properly.

To learn more about your privacy choices, please see How can you change your privacy choices? below.

The technologies we use include :

1. 1. • Cookies are small text files that are stored on your computer when you visit a website so that information can be saved between visits, such as your login details or language preferences. For example, cookies allow you to log in quickly to the Platform.
      • Web analytics tools such as Google Analytics, which uses cookies to analyze your use of the Application, to create reports on user and visitor activities, and to provide other services associated with the use of our Platform.
      • Analytics engines, which pull usage data from multiple sources and help manage and collect this data for use in personalization, interest-based advertising, content customization and other methods to better understand our customers’ needs and preferences.

You can remove or deactivate some of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features associated with the services offered. To learn more about your privacy choices, please see How can you change your privacy choices? below.

D. Third-party social networks

We may collect your personal information if you interact with us through our social media pages and accounts (for example, Facebook, Twitter, Instagram). For example, we collect the personal information that these social media platforms allow us to collect from our subscribers. We may also collect any content you upload to our social media pages and accounts (including photos or videos).

We may obtain and use analytical and statistical information from third-party social networks to help us measure the performance and effectiveness of the content we post on social networks, for example, by measuring impressions and clicks on content.

E. Other third parties

In some cases, we may collect personal information from other categories of third parties, but only with your consent or as permitted or required by applicable law.

4. How do we use personal information?

We limit the collection of personal information to that which is reasonably necessary to fulfill the purposes for which it was collected. We may use all categories of personal information detailed in the What personal information do we collect? section to provide you with our products and services, to manage our business operations, to communicate offers and information we believe may be of interest to you, to enhance your customer experience with us, and as permitted or required by law.

We use your personal information for the following purposes:

A. Providing our products and services

We use your personal information to provide our services, for example:

1. 1. 1. • process your requests for locums (also known as “replacements”) and confirm acceptance of locum contracts;
         • verify your identity;
         • to answer your questions;
         • respond to your requests or take or verify your instructions;
         • create, administer and maintain your accounts; and
         • manage payments related to services and use of the Platform in accordance with the terms of use.

B. Managing our business activitiesWeuse your personal information to manage our business activities, for example to:

1. 1. • inform you of changes to your account or to the services, conditions or policies of our Platform and provide you with administrative messages, updates, legal notices, technical notices or security alerts;
      • deploy and manage our Platform and IT systems;
      • manage and facilitate the use of our Platform, which may include the use of cookies and other similar technologies;
      • protect ourselves and third parties against error and fraud;
      • monitor compliance with the Terms of Use, investigate incidents and manage claims;
      • maintain our programs, products and services; and
      • comply with our contractual, legal and regulatory obligations.

C. Marketing and Advertising
We use your personal information to market our services by delivering online or email advertising relevant and personalized to you, including on social media platforms.

If you no longer wish to receive commercial e-mail messages, please let us know by following the unsubscribe instructions provided in each commercial e-mail message. For more details on how to manage your advertising preferences, see section 7 below, entitled: How can you change your privacy choices?

D. Conducting market research and data analysis
We may use your personal information to conduct market research and data analysis by tracking and analyzing your information for the following purposes:

• improve or develop new products, services and programs, and better understand our customers and their behavior;
• manage and develop our business and activities;
• improve our programs, products and services (for example, improve the Application); and
• understand how users interact with the services offered, including the Application, and ensure that they function correctly.

Wherever possible, we will use your information in an aggregated and/or de-identified form.

5. How do we share personal information?

We may share your personal information within PharmaGap and with our service providers and certain third parties for the purposes described in this Policy and in accordance with applicable law. We will not share your personal information with unaffiliated third parties without your prior consent, except as provided in this Policy or as permitted by applicable law.

A. Within PharmaGap
PharmaGap may share personal information internally with certain employees where such sharing is necessary in the course of their duties and use it for the purposes described in this Policy.

B. Professionals, principals and representatives
We may share some of your personal information with professionals, principals and their representatives only to the extent necessary to provide the services offered and for any other purposes set out in this Policy.

C. Service Providers
In the course of providing the services we offer, we may share certain personal information with third-party service providers who provide services to us. These service providers help us operate our business, technology systems and applications, internal procedures and infrastructure. We may also share certain personal information, such as name, e-mail address and other contact information, with certain service providers who provide services to us, such as contract processing, e-mail and postal mailings, data hosting, the provision of advertising and analytical services (for example, tracking the effectiveness of our marketing campaigns and analyzing the use of our websites and applications).

D. Sale or transfer of business or other transaction
We may disclose personal information to a third party in connection with a sale or transfer of business or assets or shares, merger, reorganization or financing of parts of our business (including insolvency or bankruptcy proceedings). In the event that the transaction is completed, your personal information will continue to be protected by applicable privacy laws. If the transaction does not go ahead, we will ask the other party not to use or disclose your personal information in any way and to delete it completely, in accordance with applicable laws.

E. Other Permitted Purposes
Applicable laws may permit or require the use, sharing or disclosure of personal information without consent in specific circumstances, such as to investigate suspected or actual illegal activities, to prevent such activities, including fraud, or to assist governmental and law enforcement agencies. These circumstances include those where permitted or required by law, or where necessary to protect our group of companies, employees, customers or others. In such circumstances, we will share only as much personal information as is reasonably necessary to fulfill these purposes.

F. With your consent
In addition to the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside PharmaGap in accordance with applicable law.

6. How do we manage consent?

By accessing or using the services offered by submitting information to us as part of the services offered, including through the Application, you are giving your consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, your consent may be “implied”, meaning that your permission is considered given based on your action or inaction at the time of collection, use or sharing of your personal information.

We generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Policy or in the terms and conditions of a specific product or service in which you have registered, participated or purchased. You may have the right to withdraw your consent under applicable law (except in limited circumstances, including legal or regulatory requirements or due to your contractual obligations with us). For information on how to manage your privacy preferences, please see How can you change your privacy choices? below.

If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is possible, we may not be able to offer you the products, services or information that you have requested or that may be offered to you, including the services offered.

7. How can you change your privacy choices?

We want you to clearly understand your choices and make informed decisions about your privacy options. Several options are available to you to manage your privacy preferences, including: managing your preferences in your account, if applicable, contacting us directly or changing your browser settings on your device or, if applicable, using the unsubscribe feature that may be offered by a third party.

A. In your account
If you have an account with us, you can update your preferences in your account in the Application.

B. When you register or by contacting us directlyYoumay choose to receive marketing communications by e-mail at the time you register for our programs, products or services, or at any time thereafter through your online account(s) and as part of the services offered, including the Application, we may also have your implied consent to send you electronic marketing communications under applicable law.

You may choose not to receive commercial e-mail communications by clicking “unsubscribe” on any commercial e-mail you receive, by following the unsubscribe instructions provided when you receive a commercial e-mail, or, in some cases, through your online account (if you have created one).

You may also withdraw your consent to other forms of marketing and advertising or to the use of your personal information for market research and data analysis purposes by contacting the Privacy Officer as indicated in the section Who do I contact if I have questions about the protection of my personal information? Please note the following regarding withdrawal of consent or modification of your privacy preferences:

1. • Although you have chosen not to receive commercial communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (for example, for customer service, product or service information, etc.). We may also need to contact you for questions or information regarding your customer service requests; and
   • There may be a delay before all of our records reflect changes to your preferences, for example, if you request not to receive personalized marketing communications from PharmaGap, your preference may not be taken into account for a promotion already in progress.

C. Use of third-party unsubscribe functionality
With your consent or where permitted by law, we may use third parties (for example, web companies or social media platforms) that use certain technologies to analyze your browsing behavior when you use the services offered. You can manage your privacy preferences in relation to certain third parties, such as Google, by using the unsubscribe function on their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features of our websites and applications.

For example, Google Analytics uses cookies to analyze your browsing behavior on our websites. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser. If you wish to disable Google’s ad settings, please visit https://adssettings.google.com/anonymous?hl=fr or use Google’s disable add-on located at https://tools.google.com/dlpage/gaoptout.

For more information on interest-based advertising or to opt-out of having your web browsing information used for behavioral advertising, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Your web browser or device may also include features or settings that allow you to opt-out of the collection of certain information via applications used for behavioral advertising purposes; for more information, please consult your browser or device settings.

We may also include links to other websites, including social media platforms, on our websites and the Application. For more information about social application plug-ins, such as “likes” on X (formerly Twitter), Facebook or Instagram and their impact on your privacy rights, please consult the appropriate social media help center (for example, the Facebook help center at https://www.facebook.com/help/).

8. How do we protect personal information?

We use administrative, physical, contractual and technical measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, taking into account, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information, regardless of where it is used or stored.

Among other things, we implement internal policies and practices that protect your personal information, including, but not limited to:

• The designation of a Privacy Officer responsible for ensuring compliance with applicable privacy laws.

• Policies and procedures that define the roles and responsibilities of our employees throughout the life cycle of personal information, limit access to such information on a “need-to-know” basis, and govern the retention and destruction of personal information.

• Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate safeguards and security standards.

Our goal is to prevent unauthorized access, loss, misuse, sharing or modification of personal information in our possession. We also use these safeguards when we delete or destroy your personal information.

9. Where we store personal information and cross-border transfers

We may share personal information with certain service providers who may not be located in your country or province or territory of residence. These service providers may also access, process or store your personal information outside the country and province where we are located and where you reside.

Consequently, when your personal information is used or stored outside the province or territory in which you reside, it may be subject to the foreign law applicable in the place where it is stored, including any law authorizing or requiring disclosure of the information to the government, government agencies, courts and law enforcement authorities of that place.

We will retain your personal information in accordance with our retention policies or as required or permitted or required by law. Once your personal information is no longer required, it will be destroyed or securely anonymized (so that the information can no longer, under any circumstances, be used to identify you, either directly or indirectly).

10. What are your privacy rights?

The rights described above may be exercised in accordance with legal requirements and restrictions:

• Your right of access: You have the right to ask us whether we are using or storing your personal information. You may also request copies of your personal information.

• Your right of rectification: you have the right to ask us to rectify any personal information that you consider to be inaccurate or misleading, and to complete any personal information that you consider to be incomplete. You may also have the right to request rectification of your personal information if the collection, disclosure or retention of such information is not authorized by law. This rectification can also be made by yourself by accessing your PharmaGap account.
• Your right to account deletion and personal data erasure : you can request the permanent deletion of your account and personal data by accessing the “General” section of your profile, then click on “Delete my account”. Once you confirm, your account and personal data will be permanently deleted. If you log in using your Facebook account, you’ll need to complete the following steps to remove access to your data;
  1. Go to “Settings and Privacy” on your Facebook account and click on “Settings”.
  2. Search for “Applications and websites”, where you’ll see all the applications and websites linked to your Facebook account.
  3. Scroll down until you find the “PharmaGap” application in the list of applications.
  4. Click on “Delete”.
  5. When you confirm the deletion, your application’s activities will be successfully deleted from Facebook.

You can also request the deletion of your account from the PharmaPlan application by sending us a request to cs@pharmagap.com.

To exercise your rights, please contact our Privacy Officer using the contact information provided in section 12 below, entitled: Who do I contact if I have questions about the protection of my personal information?

11. Changes to our Policy

We may make changes to this Policy from time to time. Any changes we make will be effective when we post an amended version of the Policy on the Application and on the PharmaGap website. If the changes we make are material, we will highlight them when required by applicable law. By continuing to participate in or use the services offered after the revised Policy has been posted or after you have been notified of such update, you agree to the changes made to the Policy. If you do not accept the changes to our Policy, it is your responsibility to stop using the services. It is your responsibility to ensure that you have read, understood and accepted the latest version of the Policy. The “Effective Date” at the top of this Policy indicates the date it was last updated.

12. Who do I contact if I have questions about the protection of my personal information?

If you have any questions about how we handle your personal information, concerns, requests or wish to make a complaint, please contact us using the details below:

Privacy Officer

Michel Kassar
E-mail: mkassar@pharmaplan.ca